Ordinary meaning in tax law: hosiery goods are distinct from ready-made garments and fall outside the garments entry.

Words in a taxing entry must be construed in their ordinary commercial and popular sense, as understood by persons conversant with the subject matter. On that approach, "ready-made garments" denotes outer dress or visible clothing, while hosiery goods are knitted articles such as socks and stockings. The distinction in common usage means hosiery goods do not fall within the expression "ready-made garments" in entry No. 2 of Part IV of Schedule II to the Madhya Pradesh General Sales Tax Act, 1958. The later amendment excluding ready-made hosiery or knitted garments was treated as confirming the original plain meaning. Hosiery goods were therefore taxable under entry No. 1 of Part VI of Schedule II.

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Issues: Whether hosiery goods fall within the expression "ready-made garments" in entry No. 2 of Part IV of Schedule II to the Madhya Pradesh General Sales Tax Act, 1958.

Analysis: The Act did not define "ready-made garments" or "hosiery goods", so the expression had to be construed in its ordinary commercial and popular sense. In taxing statutes, words of everyday use are to be understood as persons conversant with the subject-matter would understand them. On that basis, "garment" was treated as an article of outer dress or visible clothing, whereas hosiery goods were knitted articles such as socks and stockings. The distinction in ordinary language between garments and hosiery was emphasised, and the later amendment expressly excluding "ready-made hosiery or knitted garments" was treated as confirming, rather than changing, the plain meaning of the earlier entry.

Conclusion: Hosiery goods are not "ready-made garments" within entry No. 2 of Part IV of Schedule II and are taxable under entry No. 1 of Part VI of Schedule II at four per cent. The answer is against the assessee and in favour of the Revenue.

Ratio Decidendi: Words in a taxing entry must be construed in their common and popular sense, and a term used for outer garments cannot be extended to include hosiery or knitted goods unless the language clearly so provides.

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